Veriha v. Comm'r
United States Tax Court
During 2005, P-H was the sole owner of JVT, a C corporation in the trucking business, and he actively participated in JVT's business. JVT leased the tractors and trailers used in its business from TRI, an S corporation in which P-H owned 99% of the shares of stock, and JRV, a single-member LLC in which P-H was the only member. The lease of each tractor and each trailer was governed by a separate contract. During 2005, TRI generated net income and JRV generated a net loss.
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During 2005, P-H was the sole owner of JVT, a C corporation in the trucking business, and he actively participated in JVT's business. JVT leased the tractors and trailers used in its business from TRI, an S corporation in which P-H owned 99% of the shares of stock, and JRV, a single-member LLC in which P-H was the only member. The lease of each tractor and each trailer was governed by a separate contract. During 2005, TRI generated net income and JRV generated a net loss. On their 2005 joint return Ps treated the net income from TRI as passive income and treated the net loss from JRV as a…
1Opinion of the Court
JOSEPH VERIHA AND CHRISTINA F. VERIHA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Veriha v. Comm'r
Docket No. 7099-10
United States Tax Court
139 T.C. 45; 2012 U.S. Tax Ct. LEXIS 27; 139 T.C. No. 3;
August 8, 2012, Filed
Decision will be entered under Rule 155.
During 2005, P-H was the sole owner of JVT, a C corporation in the trucking business, and he actively participated in JVT's business. JVT leased the tractors and trailers used in its business from TRI, an S corporation in which P-H owned 99% of the shares of stock, and JRV, a single-member LLC in which P-H was the only…
2Cases cited11 opinions
- Federal Deposit Insurance v. MeyerSupreme Court of the United States · 1994
- Muscarello v. United StatesSupreme Court of the United States · 1998
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Schwalbach v. CommissionerUnited States Tax Court · 1998
- Schaefer v. CommissionerUnited States Tax Court · 1995
6 more not listed; retrieve them via the Exa API.